Under the current Omnibus IV proposal, sectors covered by the Machinery Regulation (EU) 2023/1230 are the only product sectors excluded from the 24-month transitional period granted to all other sectors affected by the legislative package. While other industries would benefit from a two-year adaptation period for mandatory electronic Declarations of Conformity, machinery manufacturers would have to comply directly at the date of application of the Machinery Regulation in January 2027, with no additional transition period.
This represents a significant shift. The Machinery Regulation, as adopted, explicitly allows manufacturers to provide the DoC either on paper or in digital form. Omnibus IV would remove this choice and make digital provision mandatory from January 2027, without the two‑year adaptation period granted to other sectors. This discrepancy raises serious implementation concerns. The machinery sector is characterised by long product development cycles, complex value chains, and significant upfront investment. The requirements of the Machinery Regulation were negotiated over several years to ensure practical and secure compliance. Introducing mandatory digital requirements without any transition period would force immediate system changes, increase costs, and create legal uncertainty, particularly for SMEs.
Further concerns arise from amendments adopted by the European Parliament requiring “direct access” via QR code to each individual machine’s Declaration of Conformity. This would eliminate the option of secure landing pages where users can retrieve the relevant document by entering identifying information. Such a requirement departs from the agreed Machinery Regulation, which allows Declarations of Conformity to be provided either on paper or digitally. Implementing this change less than a year before the Regulation becomes applicable (January 2027) would increase cybersecurity risks, add administrative complexity, and impose short-term costs on companies without clear enforcement benefits.
In addition, the European Parliament proposal to extend the period during which paper instructions may be requested (24 months for consumers and 6 months for professional users) introduces legal ambiguity. The notion of “consumer” is not consistently defined across the relevant legislation, and manufacturers have no practical means of verifying the status of those making such requests.
Industry therefore calls on the European Commission, the European Parliament, and the Council to ensure Omnibus IV delivers practical, secure, and workable digitalisation measures. This is essential not only for compliance but also for Europe’s industrial competitiveness.
Specifically, we urge co-legislators to:
- Grant the machinery sector the same 24-month transitional period provided to other product sectors under Omnibus IV;
- Remove the “direct access” obligation to ensure secure and reliable access to Declarations of Conformity;
- Remove provisions that create legal uncertainty regarding paper instructions.
Digitalisation should simplify compliance, strengthen Europe’s industrial base, and ensure fair treatment across sectors. A balanced approach will ensure that Omnibus IV achieves its objective of simplification while safeguarding competitiveness and legal certainty.
